Complying with CLP when making or importing candles : August 2024.
Date: 2024-08-21
Institutions: European Chemicals Agency
Subjects: chemical product, chemicals legislation, dangerous substance, market access, product safety

Complying with CLP when making or 
importing candles

August 2024 

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Disclaimer 

Complying with CLP when making or importing candles  

This document aims to assist users in complying with their obligations under the CLP 
Regulation. However, users are reminded that the text of the CLP Regulation is the only 
authentic legal reference and that the information in this document does not constitute legal 
advice. Usage of the information remains the sole responsibility of the user. The European 
Chemicals Agency does not accept any liability with regard to the use that may be made of the 
information contained in this document. 

Version 

Changes 

Complying with CLP when making or importing candles 

Reference: ECHA-24-R-06-EN 
ISBN: 978-92-9468-394-6 
Cat. Number: ED-02-24-829-EN-N 
DOI: 10.2823/401699 
Publ.date: August 2024 
Language: EN 

© European Chemicals Agency, 2024 
Cover page © European Chemicals Agency 

If you have questions or comments in relation to this document, please send them (quote the 
reference and issue date) using the information request form. The information request form 
can be accessed via the Contact ECHA page at: 
http://echa.europa.eu/contact  

European Chemicals Agency 

P.O. Box 400, FI-00121 Helsinki, Finland 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Title 

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Table of Contents 

1. YOU MAKE OR IMPORT CANDLES - WHAT DO YOU NEED TO KNOW ABOUT YOUR 

LEGAL OBLIGATIONS? .......................................................................................... 4 

2. IF YOUR CANDLE IS CLASSIFIED AS HAZARDOUS - HOW DO YOU KNOW? ............. 4 

2.1 Classification of the candle mixture .......................................................................... 4 

2.1.1 Sensitising substances ..................................................................................................... 4 
2.1.2 Other hazards ................................................................................................................. 5 

3. YOUR CANDLE MIXTURE IS HAZARDOUS – WHAT DOES THAT MEAN FOR 

LABELLING AND PACKAGING? .............................................................................. 5 

4. WHAT ELSE SHOULD YOU KNOW ABOUT CLP REQUIREMENTS? .............................. 5 

4.1.1 Notification to Poison Centres ............................................................................................ 5 
4.1.2 Notification to the Classification and Labelling Inventory ....................................................... 6 

5. ARE THERE OTHER LEGAL REQUIREMENTS TO CONSIDER? ..................................... 6 

5.1.1 Safety data sheets ........................................................................................................... 6 
5.1.2 Standards ...................................................................................................................... 6 
5.1.3 Notification to the SCIP Database ...................................................................................... 7 
5.1.4 REACH registration .......................................................................................................... 7 

6. WHERE CAN YOU GET MORE ADVICE? ..................................................................... 7 

 
 
 
 
 
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Complying with CLP when making or importing candles  

1. You make or import candles - what do you need to know 
about your legal obligations? 

A company based in the EU/EEA who makes or imports candles (including wax melts) needs to 
be aware that they may have legal obligations under EU chemicals regulations, and they need 
to consider these obligations before they place the candles on the EU market. Candle products 
are chemical mixtures under the EU regulations REACH and CLP.  

If a candle is classified as hazardous based on the CLP criteria (due to an added fragrance, for 
example), then the candle must comply with both the REACH Regulation as well as all the 
requirements of the CLP Regulations before it is placed on the market.  

2. If your candle is classified as hazardous - how do you 
know?  

The classification of a candle will depend on the classification of the different ingredient 
substances that go into the product and their concentration in the final mixture. You should 
obtain information on the classification of each ingredient, including fragrance oils, from your 
suppliers (the suppliers of the ingredients if you are a candle maker or the non-EU supplier of 
the imported candle if you are an importer). The relevant information will be in Section 3 of 
the safety data sheet (SDS) provided by the supplier.  

Candles are primarily made up of waxes which themselves are normally not classified in 
accordance with CLP. However, candles often contain additives for fragrance and colour, some 
of which may be hazardous. The most common hazardous property related to these additives 
is sensitisation, i.e., they may cause allergic reactions. Fragrance substances are often skin 
sensitisers, some might also be respiratory sensitisers. Candle dyes can also be classified as 
hazardous, but their concentration in the final candle mixture is normally very low, and 
therefore they are seldom relevant for the classification of the final mixture. 

2.1 Classification of the candle mixture 

To classify a mixture, you need to determine its health, environmental and physical hazards 
based on the criteria of the CLP Regulation. The ECHA website, especially the web pages on 
mixture classification, may be useful as a starting point: 

https://echa.europa.eu/support/mixture-classification 

The information to enable you to determine the classification of the final mixture should be 
available in the SDS provided by the suppliers of fragrances or colourants. 

2.1.1 Sensitising substances 

A sensitising substance may have a more or a less severe classification and the concentration 
limit affecting the classification of a mixture in which that substance is present will be different 
for the different categories. The possible hazard classes and categories and the respective 
concentration limits are: 

-  Skin sensitiser category 1A: concentration limit of 0.1% 
-  Skin sensitiser category 1 and 1B: concentration limit of 1% 

The mixture would, in the presence of such a skin sensitising substance at a relevant 
concentration, be classified as Skin Sens. 1. This would require the use of the hazard 
statement H317 “May cause an allergic skin reaction” and the use of the relevant pictogram 
and precautionary statements on the label. 

 
 
Complying with CLP when making or importing candles 

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If the final candle mixture does not contain any sensitising ingredient substance above the 
relevant classification limit, it will not be classified as sensitising. However, if any of the 
sensitising substances is present at a concentration at or above one tenth of the classification 
concentration (e.g., at or above 0.1 % of a Skin Sens. 1B substance or 0.01 % of a Skin Sens. 
1A substance), the substance must be mentioned on the label using the statement EUH208 
‘Contains (name of fragrance/substance). - May produce an allergic reaction.’ Such a 
statement serves to warn users who are already sensitised to a particular substance. 

In some cases, for particularly potent sensitisers with specific concentration limits for 
classification, the limit of elicitation (indication on labels and the SDS) can be even lower. Such 
substances are not commonly used, and it is most likely that the 0.1 and 1% limits will be 
applicable in the vast majority of cases related to candles. 

If the composition of the perfume blend is not available, you may be able to classify your own 
mixture based on the classification of the perfume blend. For example, if the mixture contains 
10 % of a perfume blend that is classified as sensitising, then the candle mixture is likely to 
contain more than 1% of a sensitiser and must be classified as Skin Sens. 1. 

2.1.2 Other hazards 

Other human health hazards, such as skin irritation, or in rare cases even other, more severe 
hazards, may be associated with certain fragrances or colourants. These – and the possibility 
to replace such substances with less hazardous options - will need to be considered on a case-
by-case basis by suppliers who know the full composition of the candle, the fragrances and the 
colourants. 

An environmental classification may also be required in some cases, although this is less likely. 

3. Your candle mixture is hazardous – what does that mean 
for labelling and packaging?  

If the candle mixture is classified as hazardous, or where the statement ‘Contains (name of 
sensitising substance). May produce an allergic reaction’ is required, then the candle must be 
labelled and packaged in accordance with CLP before it is placed on the market.  

The obligation to classify a substance or mixture lies primarily on the importer or manufacturer 
of the substance or mixture, but the obligation to ensure that a label is CLP-compliant lies with 
every supplier in the supply chain. 

A hazardous mixture must be packaged in packaging that complies with the CLP rules for 
packaging. A CLP label cannot be applied directly to a candle wax, as the candle wax is the 
mixture and not packaging. Further, an open glass container, aluminium foil used for tea 
lights, or an openwork paper box are not considered as adequate packaging for hazardous 
mixtures under CLP. A candle in such a container must be supplied in packaging that complies 
with the requirements of CLP. The label must be firmly affixed to the surface of the packaging 
immediately containing the candle, and positioned on the side of the packaging, so that its 
horizontally placed text can be easily read.  

For small candles, certain labelling exemptions may apply. 

4. What else should you know about CLP requirements?  

4.1.1 Notification to Poison Centres 

If a candle mixture is classified as hazardous to human health or hazardous due to its physical 
properties and is placed on the market, a poison centre notification (PCN) must be completed. 

 
 
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Complying with CLP when making or importing candles  

An important part of the PCN is the UFI (unique formula identifier), which is required to be 
placed on the label. The UFI will primarily be used by poison centres in the event of an 
emergency call as it helps to accurately identify the mixture. The timing for including the UFI 
on the label of the candle should coincide with the submission of the PCN. 

You must create a UFI code for the mixture that you place on the market. If you receive a UFI 
from your supplier for the perfume blends or other components in your candle, you cannot 
reuse that UFI as the UFI of your candle. You can use them, though, as part of your PCN 
dossier when describing the composition and in the absence of other information. 

A PCN must be completed in each Member State where the hazardous mixture is placed on the 
market. 

Detailed information and guidance on PCN submissions and the UFI code is available at: 

https://poisoncentres.echa.europa.eu/ 

4.1.2 Notification to the Classification and Labelling Inventory 

If you are importing a candle, a perfume blend or any other mixture or a substance to make a 
candle, you may have the obligation to submit a notification to the Classification and Labelling 
Inventory. Hazardous substances, imported as such or in mixtures, need to be notified to this 
inventory, regardless of their tonnage. 

You can find more information on these notifications, as well as advice on how to notify, at: 

https://echa.europa.eu/regulations/clp/cl-inventory 

Are there other legal requirements to consider? 

4.1.3 Safety data sheets 

Safety data sheets (SDS) are required for all hazardous mixtures placed on the market for 
industrial and professional users. If an SDS is required, then it must be compiled in accordance 
with Annex II to the REACH Regulation. Therefore, if your candle mixture is hazardous or 
contains hazardous substances as outlined in the REACH Regulation, you will also need to 
compile an SDS if you supply for professional use, for example, to restaurants. 

Selling directly to consumers does not require you to produce or pass on an SDS to them; the 
label must give all the consumer information required.  

If you are not supplying directly to the end user, for instance if you supply candles to be sold 
further, then you will need to provide an SDS to the distributor/retailer. 

If you need to compile an SDS, or want to check the legal conformity of the ones you receive, 
you can refer to the Guidance on the Compilation of Safety Data Sheets, at: 
https://echa.europa.eu/guidance-documents/guidance-on-reach 

4.1.4 Standards 

There are three standards for candles which do not come under the remit of chemicals 
authorities. Normally, these are covered by national authorities for consumer products. The 
standards are:  

- I.S. EN 15426 CANDLES - SPECIFICATION FOR SOOTING BEHAVIOUR  

- I.S. EN 15493 CANDLES - SPECIFICATION FOR FIRE SAFETY  

- I.S. EN 15494 CANDLES - PRODUCT SAFETY LABELS 

 
 
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4.1.5 Notification to the SCIP Database 

Candles are considered as a ‘combination of a mixture and an article’. The SCIP database, 
established due to certain obligations set out in in the Waste Framework Directive, contains an 
article category that covers ‘Candles and similar articles’. Notification of articles to the SCIP 
database is required if an article contains a Substance of Very High Concern at a concentration 
above 0.1% w/w. For example, the SCIP database contains notifications of candles that 
contain boric acid in their wick. 

Information on SCIP notifications is available at: 

https://echa.europa.eu/tools  

4.1.6 REACH registration 

As a candle maker, you are a downstream user, and thus the REACH registration obligations 
are unlikely to apply to you. However, if you do import a substance as such or in a mixture 
from outside the EU/EEA, you might have to register the substance. The registration obligation 
applies to substances imported at quantities of one tonne or more per year, unless the 
substance is specifically exempted in the REACH Regulation.  

5. Where can you get more advice? 

Information on CLP in general, as well as specifically on labelling, is available on the ECHA 
website, under ‘Guidance on CLP’: 

https://echa.europa.eu/guidance-documents/guidance-on-clp 

If you have specific questions, you can contact the national CLP helpdesk of your country. The 
contact details of national CLP helpdesks are available on the ECHA website: 

https://echa.europa.eu/support/helpdesks/ 

 
 
 
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